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Petitioner filed the petition on December 27, 2005. In it,
petitioner stated that he was appealing the notice of
determination and wanted a redetermination of the additions to
tax. The only specifically listed errors, as required by Rule
331, were: (1) That petitioner was denied his right to a fair
hearing; (2) that the filing of the Notice of Federal Tax Lien
was erroneous; and (3) that the balance due on the Notice of
Federal Tax Lien was erroneous.
Discussion
Respondent moved for summary judgment on all issues pursuant
to Rule 121. Summary judgment is intended to expedite litigation
and avoid unnecessary trials. Fla. Peach Corp. v. Commissioner,
90 T.C. 678, 681 (1988). A motion for summary judgment may be
granted if there is no genuine issue as to any material fact and
a decision may be rendered as a matter of law. See Rule 121(b);
Electronic Arts, Inc. v. Commissioner, 118 T.C. 226, 238 (2002).
The moving party bears the burden of showing that there is no
genuine issue of material fact, and factual inferences will be
read in a manner most favorable to the party opposing summary
judgment. Bond v. Commissioner, 100 T.C. 32, 36 (1993);
Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985). The party
opposing summary judgment must set forth specific facts which
show that a genuine question of material fact exists and may not
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